Re[2]: Reply to: Observed biological effects vs regs

[sandy_perle@email.fpl.com]

     Rob,
     
     I agree totally with your comments regarding the over-regulation of 
     ALARA if one is being required to maintain dose below 0.5 rem. We 
     don't have that problem in the commercial power reactor area, yet. 
     Yes, we are asked to provide documentation on exposures and if we see 
     an individual who appears to be an outlier amongst the general work 
     population, to discuss it. I would also say that for the most part, we 
     are doing more with less, still maintaining worker's dose below 3 
     rem/yr with an average dose of about 500 to 600 mrem/yr. So, it can be 
     done, without increasing cost. These comments pertain to an operating 
     reactor. I am not addressing the situation where a new reactor may be 
     built with its associated engineering and safety costs. However, since 
     the nuclear utilities have been committed to maintaining dose below 5 
     rem for many years now, way before the new part 20 was implemented 
     (via pressure from INPO), the design features are already in place.
     
     I think that there are some in this discussion who ARE in fact 
     recommending that the dose limits be extended to a higher pseudo BRC 
     value. 
     
     As stated, I agree that we should keep the limits at 5 rem/yr and 
     allow us to use our professional judgment as to how we maintain the 
     exposures below that value. We already do that. I just disagree with 
     the comments that nothing needs to be done until we exceed that value. 
     ALARA does include the R as you stated, but reasonable infers that 
     somethings are done ... in a proactive process, not in retro-response.
     
     BTW, I believe that you meant that we are required to maintain dose 
     below 5 rem TEDE, not CEDE.
     
     Regards,
     
     
     Sandy Perle
     Supervisor Health Physics
     Florida Power and Light Company 
     Nuclear Division
     
     (407) 694-4219 Office
     (407) 694-3706 Fax
     
     sandy_perle@email.fpl.com
     
     HomePage: http://www.lookup.com/homepages/54398/home.html >



>>Most of what I've read in this forum is not necessarily calling for a 
relaxing of regulations, rather, allowing them to be followed as written. 
The occupational dose limit is 5 rem CEDE per year in the US, but we are 
asked to spend huge sums of money to make sure that radiation workers don't 
receive 0.5 rem.  The concept of ALARA has lost it's R.<<